Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 923
Makati City

PEOPLE OF THE PHILIPPINES

Complainant,
-versus-

Criminal Case no. 56789

For: Slavery

LADY TREMAINE
Accused,
xx----------------------------xx
PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable

Court, respectfully states:
1. That accused is currently being charged of the crime of Slavery as
defined in Article 272 of the Revised Penal Code;
2. That no bail has yet to be filed pending any means detention that may
befall our client;
3. That the prosecution's evidence of guilt against accused, however, is
weak as there is no direct evidence that will point to the accused to
have committed the said charges against them. The records will show
that accused was maliciously implicated in the case through the
sworn statements of ELLA TREMAINE, in which the truth of the said
statement have not yet been proven;

4. That there is no other physical or documentary evidence to show that

accused is guilty of the crime charged;
5. That the burden of showing that evidence of guilt is strong is on the
prosecution, and since this fact is not satisfactorily shown, accused is
entitled to bail as a matter of right during the pendency of the criminal
case.
WHEREFORE, upon prior notice and hearing, it is respectfully
prayed of this Honorable Court that accused LADY TREMAINE, be
allowed to post bail for her temporary liberty before the start of the
trial of the criminal charge against her.
Other just and equitable reliefs are likewise prayed for.
Respectfully Submitted
24 November 2014
City of Makati
ATTY. ANGELO CARLO T. TALATALA
Counsel for the Accused